All DOT testing that takes place after June 30, 2018 must be done using the newest DOT Custody and Control Form which was approved on August 8, 2017. The DOT gave a grace period from the approval date until June 30th, 2018, where the old CCFs would still be acceptable, but that deadline is fast approaching.

This means that those who are regulated under the DOT, be they third part administrators, collectors, laboratories or Medical Review Officers, MUST use the the “new” CCF after the June 30th.

Consequences of Wrong CCF Used

If a service agent does inadvertently use the incorrect CCF after the cut-off date it will be deemed a Correctable Flaw. This means that whoever used the form will need to provide a Memorandum for Record to the laboratory and Medical Review Officer stating that the incorrect form does in fact has ALL the appropriate information required to run a valid DOT drug test.

The MFR must also state the reason the wrong form was used, either inadvertently (simply in error) or because it was the only form available to be able to perform the testing. The memorandum must also include statements as to what steps are being taken so that this problem, use of the wrong form, will not occur again.

If the correction does not place as per regulations, within an appropriate time frame, the test will be cancelled. You can check out the requirements of the regulation here.

Differences Between Old and New CCFs

The old CCF has been in use since 2010, with the changes for an updated approved and put forth on August 8th, 2017 to accommodate the changes to the DOT panel and a minor administrative update.

• In Step 1D: removal of the letters “DOT” and the associated checkbox and hash line prior to “Specify DOT Agency”.
• In Step 5A: Addition of the four new analytes added to the DOT testing panel; oxycodone (OXYC), oxymorphone (OXYM), hydrocodone (HYC), and hydromorphone (HYM). Removal of the analyte methylenedioxyethylamphetamine (MDEA).

Where Can New Forms be Obtained?

You can contact your Department of Health and Human Services (HHS) – certified laboratory to obtain the revised CCF. You can find a list of HHS approved laboratories here.

You can still use the eCCF as long as the laboratory has been approved through the HHS National Laboratory Certification Program to use that specific eCCF, and they have updated to using the new, approved form. You can find a list of laboratories which have been approved to use the new eCCF here.